Much of the basic framework for CTSA enquiries (including into
valuations) is similar to the framework for Income Tax Self
Assessment (ITSA).
You need to be sure that an enquiry has been opened before
seeking information from the company or questioning a valuation in
a CTSA case. For the purposes of the enquiry window, you should
assume that the return was filed on time unless the Inspector
advises you otherwise. As with ITSA, you should use form Val 222 if
you wish an enquiry to be opened into a company's tax return.
If you reach an agreement on value and notify it to the
Inspector in the normal way, the Inspector will close the enquiry
either then or when any other outstanding issues are settled or
need to be brought to a head.
No unagreed valuation should be included in a notice of
closure issued by the Inspector until the Appeals Team has been
consulted. (See Chapter 117 of this manual
SVM117000.)
You need to be aware of the separate information powers for
CTSA (set out in the Enquiry Manual EM2200). If you face difficulty
in obtaining information, you should ask the appropriate Inspector
to use the relevant information powers at an early stage. If you
are in any doubt as to which information power is appropriate, you
will need to liaise closely with the relevant Inspector.
| Additional Guidance: SVM150000 |
